On 13 August 2026, the UK tax authority, HMRC, published their Guidelines for Compliance for Short Term Business Visitors.1 The guidance consolidates HMRC’s existing guidance on the tax, payroll, and social security treatment of short-term business visitors to the UK and identifies common areas of compliance risk.
WHY THIS MATTERS
HMRC have identified tax, social security and payroll reporting compliance in respect of short-term business visitors (STBVs) to the UK as one of the higher risk areas for employers and employees.
This new guidance is designed to help both employers and employees comply with their obligations in the UK, and to prevent errors.
This guidance does not represent a change in law or HMRC policy but helps consolidate all the existing guidance in one place.
Further details
The new guidance is designed to help employers and employees comply with their UK tax and social security obligations for STBVs.
HMRC are increasingly focusing on STBVs as part of their employer compliance reviews, and common issues identified include:
- Employers assuming that STBVs are not taxable in the UK under the terms of a double tax treaty when the tax treaty conditions are not met.
- Employers failing to operate PAYE for STBVs on the assumption that there is no payroll requirement for STBVs if they are treaty exempt.
- Employers assuming that the social security treatment will mirror the tax treatment.
The purpose of the new guidance is to provide practical support in the following areas:
- The income tax treatment of STBVs, including consideration of the tax treaty conditions as well as areas of particular difficulty such as the economic employer test and the 60-day rule.
- The UK payroll obligations in respect of the STBV, including special PAYE arrangements.
- The social security treatment of the STBVs.
- Guidance on common errors and areas of risk identified by HMRC, as well as what records and evidence should be retained, and what to do is mistakes are made.
KPMG INSIGHTS
This guidance highlights that HMRC see STBV as a risk area for employers, and an area of focus in the employer compliance reviews.
We recommend that employers review their processes in respect of STBVs in light of this guidance, to help ensure that they are compliant.
HMRC have recently reaffirmed that its Guidelines for Compliance2 are increasingly relevant to how it assesses taxpayer behaviour in enquiries and compliance interventions. While they are not legislation, they are likely to be used as an important reference point when HMRC considers whether businesses have taken reasonable care, particularly in complex or cross-tax areas.
If employers have any questions or concerns about this guidance and appropriate next steps, please contact a member of the KPMG in the UK GMS team (see the Contacts section).
ENDNOTES:
1 GOV.UK, “Help with short-term business visitors — GfC19,” published on 13 August 2026.
2 GOV.UK, “Guidelines for Compliance,” published on 6 October 2022.
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